Florida health regulators use the honor code to police assisted living facilities, relying on owners and administrators to report to the state when an employee is accused of a crime such as fraud.

But when Tiffany Gordon was accused last year of bilking Miami's cash-strapped public hospital out of more than $83,000 by creating “ghost employees” and securing them paychecks, she both owned and ran the Intraqual Premier ALF.

She continues to run the Miami Gardens facility from her home — where she is under house arrest.

That may soon change, however. Late last week, after The Miami Herald inquired how someone could run an ALF — attending to the many needs of frail elders and disabled people — while on house arrest, the state Agency for Health Care Administration filed an administrative complaint against Intraqual Premier, seeking to revoke its license. Under new state laws, ALFs must report to the state when owners or administrators are criminally charged, rendering them ineligible to work with vulnerable clients, such as frail elders and people with disabilities.

Gordon, 35, could not be reached for comment. Her attorney, Seth LaVey, declined to discuss Gordon or Intraqual Premier, and said he instructed her not to discuss the case, either.

“She maintains her innocence, and has done so from the day we took the case,” LaVey said, through a staffer in his office.

When Gordon was arrested last September, she held a financial watchdog role, overseeing the work of a private agency that supplied temporary workers to Jackson Memorial Hospital.

She also operated Intraqual, at 19117 NW 33rd Ave., which was licensed by the state in November 2010 as an assisted living facility with an “extended congregate care” classification. That license allows the home to provide a significantly higher level of care than most ALFs — stopping short of the services nursing homes provide. In licensure records, Gordon is listed as director, chief operating officer, president and part-owner. She also is listed as both administrator and chief financial officer.

Last September, Miami-Dade police detectives arrested her, and charged her with fleecing the struggling public hospital out of $83,000.

Police say the scam went like this: Gordon hired two pals and paid them $49,301 and $34,323 mostly to do nothing. One of Gordon’s alleged confederates, Janet Lockwood, collected $17,000 from Jackson for four months while Lockwood was attending U.S. Navy boot camps in Michigan and Illinois. Most of the money was kicked right back to Gordon, police said.

In documents, a detective said the hospital uncovered the scheme in July 2010, when an internal auditor told police she had learned that Gordon had “committed fraud in excess of $300,000 for payments to temporary workers.”

Some of the temps had been paid for some hours they did not work, while others were paid to do absolutely nothing, a detective wrote. At the time, Gordon was the Jackson auditor in charge of overseeing the temporary employee company, including authorizing workers’ time sheets.

Police said Gordon had strongly recommended that Lockwood and another friend be hired at Jackson, though “they did not meet the minimum qualification criteria,” for their jobs.

In a charging document dated Sept. 8, Gordon faces three counts of unlawful compensation by a public employee, operating an organized scheme to defraud, and official misconduct by a public employee. She is being tried by State Attorney Katherine Fernández Rundle’s public corruption unit.

Gordon was originally freed on $30,000 bond while she awaited trial, but her bond was revoked on Oct. 31, shortly after she was charged with driving with a suspended license/habitual. Miami-Dade Circuit Judge Milton Hirsch placed her on house arrest the next day.

Under Florida law, ALFs cannot be owned or operated by someone who has been convicted of certain crimes — such as fraud — or charged with them and awaiting trial. ALF operators who become “aware that an employee has been arrested for a disqualifying offense” must fire such an employee, or place them in a job not subject to state background screening laws, the health care agency wrote in its complaint.

The law allows AHCA to “deny, revoke and suspend any license” held by an owner or administrator charged with a crime, and to impose administrative fines, the complaint says.

Gordon has 21 days to respond to the state’s administrative complaint.

Gordon is not the first Floridian who ran an ALF while awaiting trial on significant fraud charges.

Arturo Godinez ran two of South Florida’s largest assisted living facilities — with among the worst records for allegations of death and neglect — until AHCA removed him, about three weeks before he was convicted of racketeering, conspiracy and participating in an organized scheme to defraud. The Statewide Prosecutors’ Office said he was part of a far-flung conspiracy to sell counterfeit, stolen and relabeled medications to unsuspecting pharmacies and consumers.

Godinez was indicted in 2003. For the next nine years he ran the two ALFs in which one elderly man plunged to his death from the balcony of a third-floor Alzheimer’s wing, one woman, her mind ravaged by dementia, drank from a bottle of Pine Sol and died 10 days later, and yet another woman wandered from her ALF and was found two days later lying near railroad tracks — starving, dehydrated and comatose, her body riddled with painful red ant bites, sending her into shock.